Free Stipulation - District Court of California - California

Case 5:07-cv-05025-JF

Document 13

Filed 11/30/2007

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Thomas M. Herlihy (SBN 83615) Laura E. Fannon (SBN 111500) KELLY, HERLIHY & KLEIN LLP 44 Montgomery Street, Suite 2500 San Francisco, CA 94104-4602 Telephone: (415) 951-0535 Facsimile: (415) 391-7808 Attorneys for Defendant PENN TREATY NETWORK AMERICA INSURANCE COMPANY

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

GLORIA McCARROLL, Plaintiff, vs. PENN TREATY NETWORK AMERICA INSURANCE COMPANY, and DOES 1 through 10, inclusive, Defendants.

CASE NO. 5:07-cv-05025-JF STIPULATION RE EXTENSION OF TIME FOR DEFENDANT TO ANSWER, MOVE OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT

STIPULATION EXTENDING TIME FOR RESPONSE TO COMPLAINT CASE NO. 5:07-cv-05025-JF

Case 5:07-cv-05025-JF

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Filed 11/30/2007

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STIPULATION Pursuant to Local Rule 6-1(a), plaintiff Gloria McCarroll and defendant Penn Treaty Network America Insurance Company, by and through their respective counsel, hereby stipulate and agree that defendant shall have a further extension of time, to and including December 14, 2007, to answer, move or otherwise respond to the Complaint. This further extension is needed because the parties are very near settlement and are concluding their negotiations. The parties believe that this further extension will preserve the court's resources by avoiding unnecessary motion practice or other pleadings that would be required in the absence of this further extension. No modification of any court deadlines will be occasioned by this extension. IT IS SO STIPULATED. Respectfully submitted, Dated: November 30, 2007 KELLY, HERLIHY & KLEIN, LLP

By:___________/s/________________ Laura E. Fannon Attorneys for Defendants PENN TREATY NETWORK AMERICA INSURANCE COMPANY

Dated: November 30, 2007

FLYNN, ROSE & PERKINS

By:___________/s/________________ Gary S. Rose Attorneys for Plaintiff GLORIA MCCARROLL

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STIPULATION EXTENDING TIME FOR RESPONSE TO COMPLAINT CASE NO. 5:07-cv-05025-JF